Develop and implement detailed operating procedures, including checklists, which fully implement its procurement policy and HUD requirements.

Ensure that its executive director obtains appropriate procurement training.

Work with the Authority to develop a formalized process, such as a checklist, to use when conducting initial certifications and annual recertifications, which would help to ensure that it follows HUD requirements for its public housing program.

Require the Authority’s executive director to obtain appropriate training regarding public housing occupancy requirements.

Require the Authority to conduct a 100 percent review of its tenant files to ensure that tenants’ rents are accurate and the proper income, asset, and medical expenses are complete and documented in the tenant files.

Monitor the Authority after the recommended training and tenant file reviews are complete to ensure that the executive director understands and properly implements public housing occupancy requirements.

Require the Authority to address actual or potential conflict-of-interest relationships in its Admissions and Continued Occupancy Policy.

Work with the Authority to develop a plan to ensure that a third party reviews the initial tenant certifications and annual recertifications with an actual or potential conflict of interest.

Ensure that the Authority’s board of commissioners and staff receive HUD-approved training on conflicts of interest.

Monitor the Authority to ensure that initial tenant certifications and annual recertifications with an actual or potential conflict of interest are appropriately handled.

Require the Authority to develop and implement detailed policies and procedures to address collections, tracking, and use of its laundry machine revenue.

Require the Authority to determine how much laundry machine revenue was not deposited into its accounts and used for eligible purposes and reimburse its program from non-Federal funds.

Monitor the Authority to ensure compliance with its new laundry machine revenue policies.

Provide documentation to show that $793,101 paid to the City for legal services was cost beneficial. Based on the documentation, it should reimburse its Housing Choice Voucher Program from non-Federal funds for any amount that exceeded the cost savings.

Follow the terms of the agreement, HUD requirements, and its own policies and procedures to ensure that any intergovernmental agreements for goods and services are in compliance.

Review the 17 travel cardholders with purchases that occurred without a travel authorization and the 6 travel cardholders with purchases that were not supported to determine whether the purchases were allowable, proper, and paid in full by the cardholder, taking appropriate administrative actions as necessary. These unsupported purchases totaled $6,407. However, a total of $5,780 remains after deducting the duplicate amount of $627 addressed in Recommendation 1C.

Perform an analysis of the 3,045 travel card purchases with indications that they were unauthorized or ineligible to identify potential violations and to address any unauthorized purchases identified. OCFO should perform a review of identified transactions to determine whether they were allowable, proper, and paid in full by the cardholder, taking appropriate administrative actions as necessary.

Refer the 15 ineligible travel card transactions totaling $5,393 to the appropriate program office and obtain a response regarding what administrative actions were taken to resolve the violations. If no actions were taken, OCFO should request support to show why no corrective actions were taken.

Strengthen internal monitoring efforts regarding government travel card use to identify potentially improper, illegal, or erroneous transactions. Such efforts should include data mining to detect instances of delinquency, fraud, and misuse.

We also recommend that the Director of HUD’s Departmental Enforcement Center evaluate the apparent conflict-of-interest situations in this report and pursue administrative sanctions if warranted.